Chemical Inventory ProgramsTriumvirate Environmental presents:
Meet the PresenterSchuyler Stuart, Life
Sciences Operations Manager
• X Years Experience
• Fact A
• Fact B
• Fact C
Cell Phone: 518-569-1424
Email: [email protected]
Learning Objectives
Regulatory Drivers
Financial and Operational
Drivers
Improve Onsite Safety and
Compliance and Reduce Costs
Chemical Inventory Life
Cycle
Plan and Strategy
Development
Regulatory Landscape
EPCRA (Emergency Planning Right to Know ACT)
Hazard Communication
Local Authorities
• Fire Department
• Waste Water Agencies
CFATS (Chemical Facility Anti-Terrorism Standards)
EPCRA – Codified in 40 CFR
Parts 355, 370 and 372
• Part 355 – Emergency Planning
and Notification
• Part 370 – Hazardous Chemical
Reporting: Community Right-to-
Know
• Part 372 – Toxic Chemical
Release Reporting: Community
Right-to-Know
EPCRA – 4 Major Provisions
• Emergency Planning
(Section 301-303)
• Emergency Release Notification
(Section 304)
• Hazardous Chemical Storage
Reporting Requirements
(Section 311-312)
• Toxic Chemical Release Inventory
(Section 313)
Sections 311/312 Community
Right-to-Know Requirements
Section 311 requires submittal of MSDSs or chemical lists to the SERC, LEPC and/or local fire dept.
Section 312 requires submittal of annual (by March 1) Tier II Chemical Inventory Reports to the SERC, LEPC and/or local fire dept.
EPCRA Inventory Checklist• Facility name, address,
location Tier II -Emergency and Hazardous Chemical Inventory
• Emergency contact
• Chemical Information:• Description
• Hazards
• Amounts
• Locations
Tier II reports are due by March 1st annually
EPCRA Inventory Checklist• CAS number
• Chemical name
• Descriptors: pure, mixture, liquid, solid, gas
• Physical and health hazards: • Fire hazard
• Sudden release of pressure
• Immediate (acute) health
• Delayed (chronic) health
Tier II reports are due by March 1st annually
• Maximum amount (range/pounds)
• Average daily amount
• Number of days on-site
• Storage codes:
• Site Plan
Tier II reports are due by March 1st annually
EPCRA Inventory Checklist
• Types of storage:• Cylinder
• Glass bottles
• Tote
• Rail car
• Etc.
• Storage conditions:• Ambient pressure
• Ambient temperature
• Confidential information
• Certification
Tier II reports are due by March 1st annually
EPCRA Inventory Checklist
OSHA – Employee Right to Know
• Hazard
Communication
Standard 1910.1200
• Lab Standard
1910.1450
“Employers must develop
systems to identify chemicals
and the associated hazards in
the work place, which must be
communicated to employees”
Flammable Permits• Facilities must maintain
flammable levels at or
below permit levels
• State Building codes
provides specific
parameters on volumes
and locations of
flammable materials.
– Flammable Class
– Control Zones
DHS CFATS (6 CFR Part 27)November 20, 2007
Purpose of Rule:• Gain information about facilities
possessing specific chemicals.
• Identify high-risk chemical facilities based on risk-based-performance standards
• Improve Security of High Risk chemical facilities
http://www.dhs.gov/chemical-security-assessment-tool
Process• Types of chemicals
• Logistics– Centralized vs. decentralized
– Size/number of buildings, rooms, storage areas
– Purchasing
• Departmental users– Chemistry
– Biology
– Facilities
– EHS
– Purchasing
– Shipping/Receiving
Process Inventory Software
Examples:
• Microsoft Excel
spreadsheet
• CisPro/ChemSW
• MSDS Online
• CambridgeSoft
• SciQuest (ERM/Site
Hawk)
• Internally Developed
System
LaunchInventory Map
Create a Strategy to collect data• Identify what is to be inventoried
• Create location guide
• Notify lab personnel
• Prepare equipment and supplies
• Create a sustainable plan to
inventory new chemicals as they
arrive onsite
Managing Your
Inventory
• Need a sustainable
system for tracking
chemicals
• Identify the correct
stakeholders to
manage the data
• Chemical inventory
reconciliation
Thank You For Attending!
• You will receive an email
tomorrow with a copy of
this presentation
• Please complete our
short survey
• Expect a transcribed copy
of the Q&A as well as a
free chemical inventory
management assessment
• Register for upcoming
webinars
http://www.triumvirate.co
m/training/events